CoPE: A Small Language Model for Steerable and Scalable Content Labeling

This paper details the methodology behind CoPE, a policy-steerable small language model capable of fast and accurate content labeling. We present a novel training curricula called Contradictory Example Training that enables the model to learn policy interpretation rather than mere policy memorization. We also present a novel method for generating content policies, called Binocular Labeling, which enables rapid construction of unambiguous training datasets. When evaluated across seven different harm areas, CoPE exhibits equal or superior accuracy to frontier models at only 1% of their size. We openly release a 9 billion parameter version of the model that can be run on a single consumer-grade GPU. Models like CoPE represent a paradigm shift for classifier systems. By turning an ML task into a policy writing task, CoPE opens up new design possibilities for the governance of online platforms.

The 2025 Foundation Model Transparency Index

Foundation model developers are among the world's most important companies. As these companies become increasingly consequential, how do their transparency practices evolve? The 2025 Foundation Model Transparency Index is the third edition of an annual effort to characterize and quantify the transparency of foundation model developers. The 2025 FMTI introduces new indicators related to data acquisition, usage data, and monitoring and evaluates companies like Alibaba, DeepSeek, and xAI for the first time. The 2024 FMTI reported that transparency was improving, but the 2025 FMTI finds this progress has deteriorated: the average score out of 100 fell from 58 in 2024 to 40 in 2025. Companies are most opaque about their training data and training compute as well as the post-deployment usage and impact of their flagship models. In spite of this general trend, IBM stands out as a positive outlier, scoring 95, in contrast to the lowest scorers, xAI and Midjourney, at just 14. The five members of the Frontier Model Forum we score end up in the middle of the Index: we posit that these companies avoid reputational harms from low scores but lack incentives to be transparency leaders. As policymakers around the world increasingly mandate certain types of transparency, this work reveals the current state of transparency for foundation model developers, how it may change given newly enacted policy, and where more aggressive policy interventions are necessary to address critical information deficits.

Who Evaluates AI's Social Impacts? Mapping Coverage and Gaps in First and Third Party Evaluations

Foundation models are increasingly central to high-stakes AI systems, and governance frameworks now depend on evaluations to assess their risks and capabilities. Although general capability evaluations are widespread, social impact assessments covering bias, fairness, privacy, environmental costs, and labor practices remain uneven across the AI ecosystem. To characterize this landscape, we conduct the first comprehensive analysis of both first-party and third-party social impact evaluation reporting across a wide range of model developers. Our study examines 186 first-party release reports and 183 post-release evaluation sources, and complements this quantitative analysis with interviews of model developers. We find a clear division of evaluation labor: first-party reporting is sparse, often superficial, and has declined over time in key areas such as environmental impact and bias, while third-party evaluators including academic researchers, nonprofits, and independent organizations provide broader and more rigorous coverage of bias, harmful content, and performance disparities. However, this complementarity has limits. Only model developers can authoritatively report on data provenance, content moderation labor, financial costs, and training infrastructure, yet interviews reveal that these disclosures are often deprioritized unless tied to product adoption or regulatory compliance. Our findings indicate that current evaluation practices leave major gaps in assessing AI's societal impacts, highlighting the urgent need for policies that promote developer transparency, strengthen independent evaluation ecosystems, and create shared infrastructure to aggregate and compare third-party evaluations in a consistent and accessible way.

Do AI Companies Make Good on Voluntary Commitments to the White House?

Voluntary commitments are central to international AI governance, as demonstrated by recent voluntary guidelines from the White House to the G7, from Bletchley Park to Seoul. How do major AI companies make good on their commitments? We score companies based on their publicly disclosed behavior by developing a detailed rubric based on their eight voluntary commitments to the White House in 2023. We find significant heterogeneity: while the highest-scoring company (OpenAI) scores a 83% overall on our rubric, the average score across all companies is just 52%. The companies demonstrate systemically poor performance for their commitment to model weight security with an average score of 17%: 11 of the 16 companies receive 0% for this commitment. Our analysis highlights a clear structural shortcoming that future AI governance initiatives should correct: when companies make public commitments, they should proactively disclose how they meet their commitments to provide accountability, and these disclosures should be verifiable. To advance policymaking on corporate AI governance, we provide three directed recommendations that address underspecified commitments, the role of complex AI supply chains, and public transparency that could be applied towards AI governance initiatives worldwide.

New Tools are Needed for Tracking Adherence to AI Model Behavioral Use Clauses

Foundation models have had a transformative impact on AI. A combination of large investments in research and development, growing sources of digital data for training, and architectures that scale with data and compute has led to models with powerful capabilities. Releasing assets is fundamental to scientific advancement and commercial enterprise. However, concerns over negligent or malicious uses of AI have led to the design of mechanisms to limit the risks of the technology. The result has been a proliferation of licenses with behavioral-use clauses and acceptable-use-policies that are increasingly being adopted by commonly used families of models (Llama, Gemma, Deepseek) and a myriad of smaller projects. We created and deployed a custom AI licenses generator to facilitate license creation and have quantitatively and qualitatively analyzed over 300 customized licenses created with this tool. Alongside this we analyzed 1.7 million models licenses on the HuggingFace model hub. Our results show increasing adoption of these licenses, interest in tools that support their creation and a convergence on common clause configurations. In this paper we take the position that tools for tracking adoption of, and adherence to, these licenses is the natural next step and urgently needed in order to ensure they have the desired impact of ensuring responsible use.

Expressing stigma and inappropriate responses prevents LLMs from safely replacing mental health providers

Should a large language model (LLM) be used as a therapist? In this paper, we investigate the use of LLMs to *replace* mental health providers, a use case promoted in the tech startup and research space. We conduct a mapping review of therapy guides used by major medical institutions to identify crucial aspects of therapeutic relationships, such as the importance of a therapeutic alliance between therapist and client. We then assess the ability of LLMs to reproduce and adhere to these aspects of therapeutic relationships by conducting several experiments investigating the responses of current LLMs, such as `gpt-4o`. Contrary to best practices in the medical community, LLMs 1) express stigma toward those with mental health conditions and 2) respond inappropriately to certain common (and critical) conditions in naturalistic therapy settings -- e.g., LLMs encourage clients' delusional thinking, likely due to their sycophancy. This occurs even with larger and newer LLMs, indicating that current safety practices may not address these gaps. Furthermore, we note foundational and practical barriers to the adoption of LLMs as therapists, such as that a therapeutic alliance requires human characteristics (e.g., identity and stakes). For these reasons, we conclude that LLMs should not replace therapists, and we discuss alternative roles for LLMs in clinical therapy.

Bridging the Data Provenance Gap Across Text, Speech and Video

Progress in AI is driven largely by the scale and quality of training data. Despite this, there is a deficit of empirical analysis examining the attributes of well-established datasets beyond text. In this work we conduct the largest and first-of-its-kind longitudinal audit across modalities--popular text, speech, and video datasets--from their detailed sourcing trends and use restrictions to their geographical and linguistic representation. Our manual analysis covers nearly 4000 public datasets between 1990-2024, spanning 608 languages, 798 sources, 659 organizations, and 67 countries. We find that multimodal machine learning applications have overwhelmingly turned to web-crawled, synthetic, and social media platforms, such as YouTube, for their training sets, eclipsing all other sources since 2019. Secondly, tracing the chain of dataset derivations we find that while less than 33% of datasets are restrictively licensed, over 80% of the source content in widely-used text, speech, and video datasets, carry non-commercial restrictions. Finally, counter to the rising number of languages and geographies represented in public AI training datasets, our audit demonstrates measures of relative geographical and multilingual representation have failed to significantly improve their coverage since 2013. We believe the breadth of our audit enables us to empirically examine trends in data sourcing, restrictions, and Western-centricity at an ecosystem-level, and that visibility into these questions are essential to progress in responsible AI. As a contribution to ongoing improvements in dataset transparency and responsible use, we release our entire multimodal audit, allowing practitioners to trace data provenance across text, speech, and video.

Language model developers should report train-test overlap

Language models are extensively evaluated, but correctly interpreting evaluation results requires knowledge of train-test overlap which refers to the extent to which the language model is trained on the very data it is being tested on. The public currently lacks adequate information about train-test overlap: most models have no public train-test overlap statistics, and third parties cannot directly measure train-test overlap since they do not have access to the training data. To make this clear, we document the practices of 30 model developers, finding that just 9 developers report train-test overlap: 4 developers release training data under open-source licenses, enabling the community to directly measure train-test overlap, and 5 developers publish their train-test overlap methodology and statistics. By engaging with language model developers, we provide novel information about train-test overlap for three additional developers. Overall, we take the position that language model developers should publish train-test overlap statistics and/or training data whenever they report evaluation results on public test sets. We hope our work increases transparency into train-test overlap to increase the community-wide trust in model evaluations.

Consent in Crisis: The Rapid Decline of the AI Data Commons

General-purpose artificial intelligence (AI) systems are built on massive swathes of public web data, assembled into corpora such as C4, RefinedWeb, and Dolma. To our knowledge, we conduct the first, large-scale, longitudinal audit of the consent protocols for the web domains underlying AI training corpora. Our audit of 14,000 web domains provides an expansive view of crawlable web data and how codified data use preferences are changing over time. We observe a proliferation of AI-specific clauses to limit use, acute differences in restrictions on AI developers, as well as general inconsistencies between websites' expressed intentions in their Terms of Service and their robots.txt. We diagnose these as symptoms of ineffective web protocols, not designed to cope with the widespread re-purposing of the internet for AI. Our longitudinal analyses show that in a single year (2023-2024) there has been a rapid crescendo of data restrictions from web sources, rendering ~5%+ of all tokens in C4, or 28%+ of the most actively maintained, critical sources in C4, fully restricted from use. For Terms of Service crawling restrictions, a full 45% of C4 is now restricted. If respected or enforced, these restrictions are rapidly biasing the diversity, freshness, and scaling laws for general-purpose AI systems. We hope to illustrate the emerging crises in data consent, for both developers and creators. The foreclosure of much of the open web will impact not only commercial AI, but also non-commercial AI and academic research.

The Foundation Model Transparency Index v1.1: May 2024

Foundation models are increasingly consequential yet extremely opaque. To characterize the status quo, the Foundation Model Transparency Index was launched in October 2023 to measure the transparency of leading foundation model developers. The October 2023 Index (v1.0) assessed 10 major foundation model developers (e.g. OpenAI, Google) on 100 transparency indicators (e.g. does the developer disclose the wages it pays for data labor?). At the time, developers publicly disclosed very limited information with the average score being 37 out of 100. To understand how the status quo has changed, we conduct a follow-up study (v1.1) after 6 months: we score 14 developers against the same 100 indicators. While in v1.0 we searched for publicly available information, in v1.1 developers submit reports on the 100 transparency indicators, potentially including information that was not previously public. We find that developers now score 58 out of 100 on average, a 21 point improvement over v1.0. Much of this increase is driven by developers disclosing information during the v1.1 process: on average, developers disclosed information related to 16.6 indicators that was not previously public. We observe regions of sustained (i.e. across v1.0 and v1.1) and systemic (i.e. across most or all developers) opacity such as on copyright status, data access, data labor, and downstream impact. We publish transparency reports for each developer that consolidate information disclosures: these reports are based on the information disclosed to us via developers. Our findings demonstrate that transparency can be improved in this nascent ecosystem, the Foundation Model Transparency Index likely contributes to these improvements, and policymakers should consider interventions in areas where transparency has not improved.